Privacy, Date & Technology Policy
Last updated: June 15, 2026
1. Purpose and Scope
“Rohr-Nagel Advisory,” “Sandpiper Creations,” “Kate Elizebeth Nagel,” and “Kate Nagel Coaching” are names and brands used in connection with the professional and business activities covered by these policies. For convenience, these policies refer to the covered practice collectively as “RNA,” “we,” “us,” or “our.”
This Privacy, Data & Technology Policy explains how RNA may collect, use, store, protect, disclose, and otherwise process personal information and confidential information in connection with our website, communications, coaching and advisory services, and practice operations.
This policy applies to prospective clients, clients, client representatives, sponsors, website visitors, and others who interact with RNA.
It is intended to complement, not replace, the confidentiality, privacy, technology, information-sharing, and other terms of an applicable engagement agreement.
For coaching engagements, RNA applies this policy together with the ethical obligations applicable to ICF Professionals.
2. Information We May Collect
Depending on the interaction or engagement, RNA may collect or receive:
Contact, professional, and business information, including names, email addresses, telephone numbers, roles, employers, and mailing addresses.
Information provided through inquiries, intake forms, scheduling tools, emails, messages, meeting invitations, surveys, assessments, or other communications.
Coaching- and advisory-related information a client or authorized representative chooses to share, including goals, experiences, reflections, decisions, organizational context, and information relevant to an engagement.
Client-provided documents and materials, including presentations, plans, reports, spreadsheets, assessment results, correspondence, and other information shared for professional purposes.
Information supplied by a sponsor, employer, organization, family office, or other authorized participant in connection with an engagement.
Engagement-administration information, including agreements, signatures, invoices, payment status, and tax or business records.
Information generated through an engagement, including session notes, authorized recordings, transcripts, summaries, shared materials, and advisory analyses.
Website and technical information, including device, browser, IP address, cookies or similar technologies, pages visited, referral source, and interactions with online forms where such information is collected through our website or service providers.
Clients should avoid providing information that is unnecessary for the requested service or that they are not authorized to share.
Clients should also use appropriate care before providing health information, privileged legal materials, regulated information, or other particularly sensitive information. Where specialized handling may be appropriate, RNA may discuss additional safeguards or alternative means of communication.
3. How We Use Information
RNA may use or process information to:
Respond to inquiries, schedule meetings, assess fit, and administer prospective or active engagements.
Deliver coaching, advisory, facilitation, assessments, and related professional services.
Prepare for and follow up on sessions.
Create client-facing materials.
Perform internal professional analysis, reflection, planning, and quality management.
Communicate with clients, sponsors, and authorized representatives in accordance with applicable engagement arrangements.
Maintain client, accounting, tax, insurance, business, and professional records.
Protect systems and investigate or respond to security incidents, complaints, disputes, or suspected misuse.
Improve our website, services, materials, processes, and technology practices.
Comply with contractual, legal, professional, ethical, regulatory, or insurance obligations.
RNA uses information for purposes reasonably related to the interaction or engagement unless RNA obtains permission, provides additional notice, or has another lawful or professionally appropriate basis for using it.
4. Confidentiality
RNA treats information shared in a professional relationship as confidential, subject to the applicable engagement agreement, this policy, professional obligations, and applicable law.
For coaching engagements, RNA maintains confidentiality consistent with the ethical obligations applicable to ICF Professionals.
Confidentiality may apply not only to session content but also to electronic communications, records, assessments, recordings, transcripts, summaries, and other information generated or received through the coaching relationship.
Confidential information may be accessed by RNA and by service providers, contractors, or professional advisers who have a legitimate need to support RNA and who are subject to appropriate confidentiality, contractual, professional, or legal obligations.
Confidentiality is not absolute. RNA may disclose information when required or permitted by applicable law, legal process, an applicable agreement, professional ethical obligations, or insurance requirements; when reasonably necessary to establish, exercise, or defend legal rights; in circumstances involving safety or emergency considerations where disclosure is legally or professionally appropriate; or with the client’s authorization.
Where appropriate and legally permitted, RNA may seek to provide notice before disclosure.
5. Sponsors, Organizations, and Information Sharing
Some coaching engagements involve an employer, sponsor, organization, family office, HR representative, or another party in addition to the individual coaching client.
For these engagements, RNA seeks to establish clear agreements about:
who is participating in or sponsoring the engagement;
what information may be exchanged;
with whom information may be shared;
for what purposes information may be shared; and
how that information will be communicated.
Unless otherwise agreed, authorized, or required by law, information disclosed by a coaching client during coaching sessions is not automatically shared with a sponsor, employer, or other third party merely because that party is paying for or supporting the engagement.
Where an engagement includes progress reporting, sponsor meetings, organizational feedback, or another defined information-sharing arrangement, RNA will seek to clarify those expectations in the applicable agreement or another appropriate documented process.
If material uncertainty arises about what may properly be shared, RNA may seek clarification before disclosing information.
6. Communications and Technology Risks
RNA uses reasonable administrative, technical, and organizational measures designed to protect information appropriate to the nature of the practice and information involved.
No method of electronic transmission, internet communication, cloud storage, or data security is completely secure or error-free. RNA therefore cannot guarantee absolute security, uninterrupted availability, or that unauthorized access, loss, interception, or other incidents will never occur.
Email, text messages, videoconferencing, shared links, online forms, and other electronic communications may involve security, delivery, interception, access-control, or compatibility risks.
Clients should use reasonable judgment about the sensitivity of information transmitted through electronic channels and may ask RNA about reasonable alternatives where appropriate.
7. Cloud Services, Vendors, and Support Personnel
RNA may use third-party providers to support scheduling, email, videoconferencing, document storage, electronic signatures, billing, payment processing, website hosting, client collaboration, transcription, cybersecurity, and other practice functions.
Those providers may process information on RNA’s behalf and may store or process information outside a client’s state or country, subject to their systems, contractual terms, privacy practices, security measures, and applicable law.
RNA seeks to select providers and configurations appropriate to the service and sensitivity of the information involved. RNA may consider provider terms, privacy practices, security features, access controls, retention and deletion settings, model-training or secondary-use settings, data-location considerations, and available administrative controls.
RNA remains responsible for meeting its own professional, ethical, contractual, and legal obligations when using technology providers and does not delegate those obligations merely by using a third-party service.
RNA also uses reasonable measures to ensure that contractors, assistants, consultants, or other personnel supporting the practice understand and comply with confidentiality and other ethical obligations relevant to their role.
RNA may change providers, configurations, and successor technologies as operational needs, security practices, professional standards, or technology evolve. This policy does not promise use of any particular vendor, platform, storage location, certification, or technical feature.
8. Videoconferencing, Recordings, and Transcription
RNA may conduct meetings through videoconferencing or other digital communication platforms.
Recording, transcription, automated processing, storage, retention, access, ownership, sharing, and deletion are distinct activities and may be subject to different terms and practices.
For coaching engagements, RNA’s practice is to obtain the client’s consent before making an audio or video recording.
Before a coaching recording begins, RNA will provide appropriate notice and obtain consent through the engagement agreement, a separate consent, meeting notice, platform notice, verbal confirmation, or another reasonable documented process appropriate to the circumstances.
Where an engagement involves a sponsor or another participant, RNA will also consider whether additional agreement or consent is appropriate based on the participants and intended use of the recording.
Where a recording or transcription service is used, the applicable provider may process audio, video, or related content to create a transcript, summary, or other authorized output.
A client may decline or prospectively withdraw consent to an optional recording. Doing so may affect the availability of recording-dependent materials or workflows. RNA may discuss reasonable alternatives where practical.
More detailed recording and records-management practices are described in the Client Records, Recordings & Digital Materials Policy.
9. AI-Enabled and Automated Tools
RNA may use AI-enabled, automated, or machine-learning-supported tools in limited practice operations, including transcription, summarization, organization, drafting assistance, research assistance, administrative support, or internal analysis.
These tools may process client-related information only when doing so:
is reasonably necessary for the agreed service or practice operation;
is appropriate to the sensitivity of the information;
is consistent with the applicable engagement agreement and this policy;
is consistent with RNA’s professional and ethical obligations; and
is permitted by applicable law and any required consent.
For coaching engagements, RNA seeks clear agreements concerning material technology use that affects coaching information or the coaching experience.
Before recording a coaching session or using AI-enabled processing for recording-derived content, RNA will provide appropriate notice and obtain any consent required by the applicable agreement, professional obligations, and law.
Before using an AI-enabled system for sensitive or confidential client content, RNA will use professional judgment regarding the purpose, sensitivity, access controls, vendor terms, data-use settings, security practices, and available alternatives.
RNA may minimize, redact, de-identify, or avoid entering information into an AI-enabled system where appropriate.
RNA does not intentionally use client confidential information to train a public or general-purpose AI model unless the client has expressly authorized that use in writing.
AI-generated transcripts, summaries, drafts, analyses, and other outputs may be incomplete, inaccurate, biased, or contextually flawed. They are supporting tools and are not substitutes for RNA’s professional judgment, client reflection, independent verification, or individualized professional services.
RNA maintains human oversight of AI-assisted output used in its work and may revise, disregard, verify, contextualize, or decline to rely on that output.
Clients should review any shared AI-assisted output for accuracy and should not treat it as legal, medical, mental-health, tax, investment, employment, or other regulated professional advice unless separately provided by an appropriately qualified professional.
RNA remains responsible for its ethical, professional, contractual, and legal obligations when using technology systems, including artificial intelligence, technology-assisted coaching tools, databases, platforms, software, and automated services. RNA does not delegate those responsibilities to the technology provider.
Where feasible and appropriate, RNA periodically reviews technology providers and practices as tools, vendor terms, security capabilities, professional standards, and applicable law evolve.
RNA may use principles from the ICF Artificial Intelligence Coaching Framework and Standards as decision-making guardrails for responsible technology use in human-delivered coaching, including principles concerning transparency, client welfare, privacy and confidentiality, human accountability, bias awareness, security, accessibility, and ongoing assessment.
This does not mean that every AI-enabled service, transcription tool, or automated feature used by RNA is itself an AI coaching system.
10. Security Practices
RNA uses safeguards designed to be proportionate to the practice and information involved. These may include access controls, authentication, encryption or secure transmission where available and appropriate, software updates, device protection, backup and recovery measures, vendor review, and confidentiality requirements for personnel and contractors.
Safeguards may change as technology, risks, available protections, and practice operations evolve.
Clients and authorized users are responsible for protecting their own accounts, devices, passwords, access links, downloaded files, and shared materials.
Please promptly notify RNA at [EMAIL ADDRESS] if you suspect unauthorized access, misdirected communications, or another security issue involving RNA information or systems.
11. Sharing and Disclosure
RNA does not sell client confidential information.
RNA may disclose information to:
service providers and contractors supporting the practice;
sponsors, employers, organizations, family offices, or authorized representatives where permitted by an applicable information-sharing agreement, client authorization, professional obligations, or law;
professional advisers, insurers, auditors, or potential successors where reasonably necessary and subject to appropriate confidentiality protections;
government authorities, courts, regulators, or other parties when required or permitted by applicable law; or
a purchaser, successor, or reorganized entity in connection with a bona fide business transition, subject to appropriate confidentiality protections and applicable law.
Nothing in this section changes any narrower confidentiality or reporting arrangement established for a particular coaching engagement.
12. Individual Choices and Rights
Subject to applicable law, contract terms, and the distinction between client-accessible materials and RNA’s private records or work product, an individual may request to access, correct, update, delete, restrict, or object to certain processing of personal information.
A person may also request to withdraw optional consent prospectively for a recording or particular processing activity.
Requests should be directed to [EMAIL ADDRESS].
RNA may need to verify identity and may decline or limit a request where permitted by law or reasonably necessary to protect confidentiality, preserve legal rights, maintain required records, protect another person’s rights, comply with professional or ethical obligations, preserve security, respond to a complaint or dispute, or protect proprietary practitioner records and work product.
RNA will not discriminate against an individual for exercising rights available under applicable law.
13. Retention
RNA retains information for periods reasonably necessary for the purposes described in this policy, the applicable engagement, and legitimate legal, tax, insurance, professional, ethical, administrative, security, and dispute-resolution needs.
For coaching engagements, RNA seeks to maintain, store, and dispose of electronic files, communications, recordings, transcripts, notes, and other records in a manner designed to promote confidentiality, security, and privacy and to comply with applicable agreements, professional obligations, and law.
RNA may securely delete, archive, de-identify, or otherwise dispose of information when it is no longer reasonably needed, subject to applicable preservation requirements or holds.
Retention does not itself determine ownership of information or materials, and retention by RNA does not create a continuing client right of access.
Category-specific practices are described in the Client Records, Recordings & Digital Materials Policy.
14. Governing Documents and Applicable Law
This policy forms part of RNA’s professional operating framework and is intended to complement any applicable engagement agreement.
If a signed engagement agreement directly conflicts with this policy, the signed engagement agreement controls to the extent of the conflict.
Effective September 1, 2026, RNA’s professional operations are based in Ohio. The governing-law, venue, and dispute-resolution provisions in the applicable engagement agreement control for that engagement.
Agreements entered into before September 1, 2026 remain subject to their existing terms unless the parties expressly amend them in a signed writing.
Nothing in this policy is intended to limit mandatory law that may apply based on the services, the client’s location, the information involved, or other relevant circumstances.
15. Changes and Contact
RNA may revise this policy to reflect changes in its practices, providers, technology, professional standards, or applicable law.
The updated version will be posted with a revised last-updated date.
For privacy or technology questions, contact [EMAIL ADDRESS].